These are some of the most important compliance deadlines and ongoing responsibilities, although not an exhaustive list of duties, to help defined contribution plan sponsors keep their retirement plan compliant with regulations in 2025 and beyond.
2025 Deadlines
Note: Dates are provided for defined contribution plans beginning January 1. If the filing due date falls on a Saturday, Sunday or federal holiday, the return/report may be filed on the next day that is not a Saturday, Sunday or federal holiday.
January 31 – Deadline for sending Form 1099-R to participants who received distributions during the previous year.
January 31 – Deadline to report income tax withheld during the prior calendar year.
January 31 – Deadline to file Form W-2 with the IRS (electronic) and provide W-2 to employees.
January 31 – Complete compilation of year-end census data (if a December 31st plan year end)
February 10 – Extended deadline to report federal income tax withheld from non-payroll payments in the previous calendar year if those withholding taxes were paid in full in a timely manner.
March 17 – Deadline for refunds to HCE for failed ADP/ACP test (for calendar year plans subject to testing); if distributions are done after this date, there is a 10% excise tax. Recordkeepers may have an earlier deadline.
March 17 – Tax deadline for Partnerships and S-Corps filing corporate tax returns and contribution deadline for deductibility (without extension) for companies operating on calendar-year fiscal year.
March 17 – Deadline for requesting automatic extensions (to September 15) of Partnership and S-Corporate tax returns.
March 31 – Deadline for reporting excise taxes for late return of excess distributions using IRS Form 5330.
April 1 – Required Minimum Distributions (RMDs) must begin for participants the year after they turn 73.
April 15 – Deadline for 402(g) excess contributions to be returned to participants.
April 15 – Tax deadline for Sole Proprietors and C-Corporations filing individual and/or partnership tax returns and contribution deadline for deductibility for unincorporated entities (without extension).
April 15 – Deadline for requesting automatic extension (to October 15) of individual and partnership tax returns.
July 29 – Deadline for distributing SMM (Summary of Material Modification) to participants if the plan was amended in 2024, unless information was included in an updated SPD (Summary Plan Description).
July 31 – Filing deadline for Form 5500.
July 31 – Filing deadline for Form 8955-SSA (identifies separated participants with deferred vested benefits).
July 31 – Deadline to apply to extend filing deadline for Form 5500 and/or Form 8955-SSA (to October 15).
July 31 – Deadline to file a qualified accountant’s audit report or limited scope audit to include in ‘Schedule H’ of Form 5500 (without extension).
September 15 – Extended due date for partnerships and S-Corporations for filing tax returns and final contribution deadline for deductibility for these entities
September 30 – Deadline for distributing Summary Annual Report (SAR) to participants if Form 5500 extension was not filed.
October 15 – Extended deadline for filing Form 5500/8955-SSA.
October 15 – Extended deadline for C-Corporations and Sole Proprietors filing tax returns for unincorporated businesses and final contribution deadline for deductibility for these entities.
November 1 – Send participants notices for Simple IRAs and 401k plans.
December 1 – Deadline to send ACA/QACA/EACA Notice, Qualified Default Investment Alternative (QDIA) Notice, Safe Harbor Notice and Automatic Enrollment/Increase Notice.
December 15 – Extended deadline for distributing SAR.
December 31 – Deadline for corrective distributions for previous year’s failed ADP/ACP test with 10% excise tax.
December 31 – Deadline to adopt a retroactive amendment if plan failed previous year’s coverage or nondiscrimination requirements.
December 31 – Deadline to amend plan to reflect discretionary changes implemented this year (exceptions apply).
December 31 – Deadline for ongoing required minimum distributions (RMDs).
Download our 2025 Compliance Calendar to help keep track of these deadlines throughout the year.
Ongoing Responsibilities
Plan Documents
Key Actions: Work with your document provider, usually your recordkeeper, third-party administrator (TPA) or attorney, to ensure you have a fully executed and updated copy of your plan document and amendments.
Timing: Ongoing
Plan Provisions
Key Actions: Review the provisions in your plan document so you can ensure the plan operates in accordance with plan documents.
Timing: Every few years
Plan Amendments
Key Actions: Amend plan documents to reflect any discretionary changes desired for the current plan year (some amendments must be made on a prospective basis). Consider amendments that will be required by SECURE 2.0, such as changes to automatic enrollment requirements, and document any operational changes made to comply with such legislation. Notify your recordkeeper and document provider of operational changes as they are made.
Timing: Annual
Plan Evaluation
Key Actions: Assess your plan and provider, considering factors like plan fees/costs, participant engagement, investment performance, fiduciary/compliance support and administration services, to ensure they still meet your needs.
Timing: Annual
Discretionary Match Notice
Key Actions: If the plan document indicates a discretionary match, the plan sponsor is required to notify both the plan administrator (PA) and participants of the match in writing.
Timing: Annual; must notify participants within 60 days after the last matching contribution has been deposited for the year and notify the PA before the first deposit of the year.
True Up Match
Key Actions: Check your plan document to see if a true up match is permitted and/or required. If applicable, determine whether it’s right for your plan.
Timing: Before plan year end
Annual Non-Discrimination Testing
Key Actions: Reach out to your recordkeeper or TPA to ensure non-discrimination tests are performed in a timely manner.
Timing: Annual, within first two months after plan year end
ERISA Bond
Key Actions: Contact your property & casualty insurance provider for details on your ERISA Fidelity Bond so you can state the amount on Form 5500.
Timing: Annual, prior to start of plan year
Loan Delinquency
Key Actions: Run a report from your recordkeeping system to identify delinquent loans.
Timing: Quarterly
Forfeitures
Key Actions: Unallocated assets in the plan should be used up annually. Review your plan document to determine an appropriate use of forfeitures, which could include paying plan fees, reducing employer contributions, or reallocating to participants.
Timing: Annual
Force Out Distributions
Key Actions: Regulations say you can cash out terminated employees with less than $1,000 and roll over those with less than $7,000 to an IRA, but your plan document may be more conservative. Confirm if your recordkeeper or TPA has an automated process in place.
Timing: Annual
Participant Fee Disclosure
Key Actions: The 404(a)(5) Participant Fee Disclosure notice must be provided at least once every 14 months to all plan participants as well as being given to new hires on or before the date they could first direct their investments. Be aware of this timing, and check if your recordkeeper is sending it on your behalf. There may also be a separate disclosure for your TPA or advisor.
Timing: Annual and before new hires are eligible
Uncashed Checks
Key Actions: Run a report to identify uncashed checks. Your recordkeeper may have an established process that involves forfeiting checks that are outstanding for more than 180 days.
Timing: 2-4 times per year
Mid-Year Non-Discrimination Testing
Key Actions: Mid-year testing is recommended for plans that have had a change in population due to acquisition or divestiture, as well as any plan interested in improving test results. Coordinate with your recordkeeper/TPA to run testing and confirm if there is a charge for it.
Timing: Annual, if applicable
Participant Beneficiary Information
Key Actions: Remind participants to designate a beneficiary and review this designation periodically.
Timing: Annual
Timely Remittance
Key Actions: Employers are required to deposit elective deferrals and loan repayments as soon as they can reasonably be segregated from the employer’s assets. For small plans, there is a safe harbor period of seven business days for the timely deposit of contributions following the day on which such amounts would otherwise have been paid to the employee as compensation.
Timing: Continuous
RMDs
Key Actions: If you have participants who meet the criteria for RMDs, contact your TPA or recordkeeper to determine if they need to have a distribution processed by December 31.
Timing: Annual
CBIZ can help you navigate the complexities of retirement plan compliance. Connect with a specialist to get started.
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